We attach the utmost importance to the protection of your data. We have established security and privacy rules aimed at ensuring the best possible protection of your data. We need to collect certain information when placing an order. However, personal data is not collected without your prior consent.

These rules apply to all company employees.

ENJIFY

Website Privacy Notice

1. About Us

This website is operated by Universal Gaming, a private company incorporated under French law with registration number 82932541400037 and headquartered at 384 Route de Rouen, 76480 Yainville (“Enjify”, “we”, “our”, “us”).

The website www.enjify.com and our mobile applications (“website”) list various digital content, such as downloadable game titles and other downloadable content (“content”). We sell on the site official keys/accounts, issued by the publisher and/or developer of the concerned Content (“Developer”), which allow the user to unlock, access, and download the concerned Content from the Developer’s platform (“Code(s)/Account(s)”). We are not the Developer of the Content and we do not own or operate the Developer’s platform.

2. To Whom Does This Privacy Notice Apply?

This privacy notice applies to individuals who access, browse, and use our website. Its purpose is to give you information on how we collect and process your personal data when you use the website. We collect personal data when you access our website, when you register on our site, when you contact us, when you send us product feedback and reviews, when you purchase Codes/Accounts and other products on our website, when you post materials on our website, when you request marketing updates, and when you participate in promotions, surveys, affiliate or partnership programs on our website.

If you are a partner of Enjify, this privacy notice applies to you just like any other user of the website. However, we will also process certain personal data about you in order to execute our partnership agreement with you.

It is important that you read this privacy notice as well as any other privacy notice or fair processing policy we may provide on specific occasions when we collect or process personal data about you, so you know how and why we are using your personal data.

3. Third-Party Links

The website may include links to third-party websites, plugins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit. Please see our cookie policy for more details on cookies and similar technologies used by third parties and how to control them.

For partners wishing to collaborate with us, we may use Youtube’s API services to access and collect the number of subscribers you currently have on your Youtube channel. We will retain this data for a period of 14 days. This information will not be disclosed to external parties and will only be used internally by our marketing team. You can review Google’s privacy rules at http://www.google.com/policies/privacy

4. Types of Personal Data We Process

“Personal data” is information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Throughout this privacy notice, we use the term “processing” to refer to all activities involving your personal data, including collecting, handling, storing, sharing, accessing, using, transferring, erasing, and destroying such data.

The personal data we collect about you depends on the particular activities carried out on our website. For example, we collect different types of personal data depending on whether you create a user account, purchase Codes/Accounts, or just browse the website. Generally, we collect and process the following types of personal data:

Identity and contact data include your name, postal address, email address, date of birth, and any personal data provided when you contact us and, in the case of instant game partners, any personal data provided as part of our partnership; Financial data include information necessary for processing payments and fraud prevention and, regarding instant game partners, all billing-related information. If you pay us by payment card, this data includes payment card numbers, cardholder name(s), security code numbers, and expiration dates. For all payment types, we will process payment data received from your payment card issuer or the payment method provider you have chosen; Transaction data include details about payments you have made and other details about products and services you have purchased from us and, in the case of instant game partners, personal data related to the administration, management, and execution of our business relationship; Technical Data may include the Internet Protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technologies on the devices you use to access our website; Usage data includes information about how you use the website, such as the services you view or search for, page response times, download errors, the length of visits, and information about page interaction (such as scrolling, clicks, and mouse-overs); and Marketing and communication data include your preferences for receiving marketing communications from us and your communication preferences. We also collect, use, and share Aggregated Data such as statistical or demographic data for various purposes. Aggregated Data may be derived from your personal data but is not considered personal data in law because this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses. Please do not provide on the website or in any communication with us any Special Categories of Personal Data and/or Personal Data relating to criminal convictions and offenses about you; or any personal data about any other person.

When we need to collect personal data by law or under the terms of a contract we have with you (for example, under our terms of sale) and you fail to provide that personal data when requested, we may not be able to perform the contract we have or are trying to enter into with you. We will notify you at the time of collecting your personal data if you are required to provide such personal data to use the website or any of our services, and whether the provision of the personal data we are asking for is mandatory.

5. How Your Personal Data is Collected

We may collect your personal data in various ways, including the following:

Direct interactions: You may give us your Identity and Contact Data, Profile Data, Financial Data, and Transaction Data by creating and managing your user account, purchasing Codes/Accounts, using IG Credits and gift cards, selecting preferences, giving product reviews, completing website forms, sharing product details, or corresponding with us by post, phone, email, SMS, social media, or otherwise. This includes personal data you provide when you participate in a contest, promotion, or survey; give us feedback; or contact us. Automated technologies or interactions: As you interact with our website, we collect Technical Data and Usage Data, including details of your device, actions and patterns, searches, sections viewed, traffic data, web logs, and other communication data and resources that you access. We collect this personal data using cookies, tracking Codes/Accounts, server logs, and other similar technologies. We may also receive Technical Data if you visit other websites using our cookies. Third-party sources: We may also receive personal data about you from third parties as listed below: (a) Transaction data from developers confirming the redemption of Codes/Accounts you purchase from us. (b) Technical data from our analytics provider, Google Analytics. (c) Identity and contact data, financial data, and transaction data from payment service providers such as PayPal, HiPay, and Paysafecard. (d) Identity and contact data, profile data, financial data, and transaction data from Transactial Limited, our Irish subsidiary, which provides various services related to the purchase and exchange of Codes/Accounts, including processing payments according to the payment method selected when purchasing the Codes/Accounts, customer services, and technical support. (e) Identity and contact data from public sources such as a company register. (f) Identity and contact data (your email address and name) when you log in using the services of Facebook or Google.

6. How We Use Your Personal Data

In general, we do not rely on consent as a legal basis for processing your personal data, but we will ask for your consent before sending you direct marketing communications by email, SMS, or other electronic means.

Marketing: We would like to send you information about our services, upcoming game releases, pre-orders, and offers that may interest you. Where we have your consent or where it is in our legitimate interests to do so, we may do this by email and/or through mobile push notifications.

If you have previously agreed to be contacted in this way, you can unsubscribe at any time using the “unsubscribe” link in emails, by changing your notification settings on your mobile device, or by contacting us using the information listed in section 13 below. You can also manage your personal data associated with your user account via the settings page.

If you agree, as part of our cookies, we will use certain technologies that allow us to see if updates and other communications we send you have been viewed and read. As explained in section 6 above, we use this information as part of our legitimate interests to develop our products and services, direct marketing, and business growth.

7. Disclosure of Your Personal Data

Except as set forth in this privacy notice, we will not disclose to any third party the personal data we collect from you or that you provide to us. We may be required to share personal data with the parties listed below for the purposes set out in section 6 above.

Internal Third Parties: Companies within our group of companies (i.e., a parent company, a subsidiary, and/or a parent company of another subsidiary) to help us provide our services. For example, our subsidiary based in Ireland, Transactial Limited, assists us in processing your payments (depending on the payment method you have chosen for the Codes/Accounts), customer services, technical support, managing cancellation rights, and, where applicable, issuing refunds or other payments. External Third Parties: Companies that provide us with products and services such as professional advisors, IT systems and support providers, data storage, IT developers, analytics companies, website hosting providers, and other service providers. Public authorities and government bodies: Entities that regulate or have jurisdiction over us. We will disclose personal data to comply with any legal obligation, if ordered by a competent court, law enforcement authority, regulatory or administrative authority, or to execute a contract with you or protect our rights, property, or safety and/or those of our staff, website users, and others. Business Activity: Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to whom we disclose personal data we collect in connection with this privacy notice to respect the security of personal data and to treat it in accordance with the law. We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for specific purposes and in accordance with our instructions. Unless prohibited by applicable law, we will notify you when your personal data may be provided to third parties in a manner other than as explained above, and you may have the opportunity to prevent this sharing at the time we notify you.

8. International Transfers

We are located in Dubai and your personal data will therefore be received and processed by us in Dubai. It may be necessary for us to disclose certain of your personal data to our trusted suppliers who provide us with products and services that help us provide you with our services. Our trusted suppliers are located in the European Economic Area. We will ensure that any international transfer of your personal data complies with applicable laws.

9. Updating Your Personal Data

It is important that the personal data we hold about you is accurate and current. Please keep us informed, using your user account settings page, if any of your personal data changes during your relationship with us. You can also contact us using the information provided in section 13 below to update your personal data.

10. Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your personal data will do so only in an authorized manner and are subject to a duty of confidentiality. You acknowledge that no entity can ensure complete security of personal data. If you have reason to believe that any of your personal data is no longer secure, please notify us immediately by contacting us using the information provided in section 13 below.

11. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

12. Your Legal Rights

Under certain circumstances, by law you have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. This enables you to ask us to provide to you, or to a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially consented for us to use or where we used the information to perform a contract with you. Right to withdraw consent: If you have given your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you wish to withdraw your consent, we will take steps to ensure that we no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. To exercise one or more of your rights in relation to your personal data, please contact us in writing using the information provided in section 13 below. You will need to provide us with information to identify you in our records, we will also need proof of your identity and address, as well as the information to which your request relates.

Please note that the settings page of your user account allows you to update, manage, and download some of your personal data, as well as to disable your user account and delete [all] personal data associated with your user account.

You have the right to make a complaint to the data protection supervisory authority. However, we would appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance using the information provided in section 13 below.

13. Contacting Us

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us via the website’s support and contact links or by logging into your user account and connecting to your user account.

14. Changes to This Privacy Notice

We will amend this privacy notice from time to time and any changes will be contained in a revised privacy notice published on the website. This version of the privacy notice was last updated on 15 February 2022, and historical versions can be obtained by contacting us using the information in section 13 above.